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Local Plan – Strategic Policies Pre-submission document representation form Please return to Cornwall Council by 5.00pm on 22 April 2013 Please complete a separate sheet for each representation you wish to make (All representations will become public) 1. Personal details.

2. Agent details (if applicable).

Name Sophie Hartfield Organisation REG Windpower Address line 1 37, Edward Street Address line 2 Address line 3 Truro Address line 4 Cornwall Postcode TR1 3AJ Telephone number

01872 226930

Email address [email protected] Q1. Do you consider that the Local Plan meets the legal and procedural requirements? Yes

Q2. A local planning authority should submit a plan for examination which it considers to be ‘sound’ – namely that it is; positively prepared, justified, effective and is consistent with national policy. Do you consider the Plan has met these tests?

Please specify the reasons below

Yes

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Representations 701-710

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Q3. Please set out below any concerns you have with the Local Plan including any change(s) you consider necessary to address these concerns. You will need to say how this change will address the concerns and it would be helpful if you could put forward your suggested revised wording to any policy or text and any evidence to support the change. Please state which paragraph or policy your change refers to and specify the reasons below: Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

2.59 Policy 15: Renewable and Low Carbon Energy.

Sustainability Appraisal Report

REG Wind welcomed and supported the apparent initial aim, stated on page 394 of the accompanying Sustainability Appraisal (January 2013), to generate 1,427MW of renewable/low carbon energy and 190MW heat within Cornwall by 2030. We are disappointed to note that the target has subsequently been removed from the policy itself (addendum to Sustainability Appraisal (February 2013)) and we feel that it is now unclear, particularly given the large amount of new residential development proposed, how much renewable energy capacity is considered to be appropriate within Cornwall, and what are the strategic aims within an authority which aspires to be a ‘green peninsula’. Policy 15 begins by stating ‘to increase use … of renewable and low carbon energy generation’. While we can accept the philosophy behind this wording we would suggest that it is government policy to reduce the use of energy, regardless of how it is generated. Policy 15 states that ‘In and adjacent to Areas of Outstanding Natural Beauty and undeveloped coast, development would not be allowed except in exceptional circumstances and should generally be very small scale in order that the natural beauty of these areas may be conserved’. We have a number of concerns regarding this policy, in particular;

• The National Planning Policy Framework (NPPF), published in March 2012, replaced Planning Policy Statement 22: Renewable Energy (PPS22). Nevertheless, as advised in the Government response to the Communities and Local Government Select Committee Report: National Planning Policy Framework, dated March 2012, until such time as the guidance review is complete, the existing supporting guidance where relevant can still be used. Therefore the Companion Guide to Planning Policy Statement: 22 Planning for Renewable Energy remains relevant. PPS 22 was quite clear (para 14) that ‘local planning authorities should not create “buffer zones” around international or nationally designated areas and apply policies to these zones that prevent the development of renewable energy projects’. Although PPS 22 has been replaced by the NPPF the Companion Guide reiterates (para 4.17) that ‘in avoiding the creation of “buffer zones”, as advised in paragraph 14 of PPS 22, authorities will still need to ensure their criteria-based policies for areas outside nationally designated areas afford appropriate protection to those areas’. We are concerned that, by using the term ‘adjacent’, draft policy 15 is essentially creating a buffer zone to the AONB.

• The policy does not explain what may constitute ‘exceptional circumstances’,

what is ‘adjacent’ or what is ‘very small scale’ and each of these may needlessly prevent important opportunities for harnessing renewable energy across a wide area of Cornwall.

• We are also concerned about the phrase ‘when assessing proposals for wind turbines on the outskirts of Areas of Outstanding Natural Beauty the status of the Area of Outstanding Natural Beauty shall be taken into account when assessing landscape impact’ within this particular draft policy as there is no indication of what may constitute ‘outskirts’. The terminology is considered vague and imprecise and causes particular concern given that there have been a number of incidents in Cornwall where wind turbines, proposed several kilometres from an Area of Outstanding Natural Beauty, have received objections from the Area of Outstanding Natural Beauty team. Even the Overarching National Policy Statement for Energy (EN-1) (July 2011) states that ‘the fact that a proposed project will be visible from within a designated area should not in itself be a reason for refusing consent’ (para 5.9.13). Although the NPS is predominantly aimed at applications to be handled by the Major Infrastructure Planning Unit (‘MIPU’) in England and Wales this NPS is likely to be a material consideration in decision making on applications that fall under the Town and Country Planning Act 1990 (as amended) (para 1.2.1).

• The potential exclusion of large scale renewable energy development within the Area of Outstanding Natural Beauty is a particular concern given that 26% of Cornwall lies within this designation (page 31 – although the SA (page 210) incorrectly states that it is 30%). This situation is exacerbated by the apparent extension of this designation by implementing a “buffer zone”, or “outskirting” policy which will, when combined with the World Heritage Site designation (18,222ha, or 5% of Cornwall according to the SA (page 210)), preclude renewable energy development within a significant proportion of Cornwall. This will ultimately place a significant burden on other areas of Cornwall in order to deliver installed renewable energy capacity.

• We are concerned about the reference to ‘undeveloped coast’ within draft policy 15. There appears to be no definition, or indication, of what may actually constitute undeveloped coast in Cornwall, the extent of this area and whether it is simply a buffer zone for the coastal AONB, or a mechanism to protect any coastal area not falling within the AONB. Objective 1 of the Cornwall Local Plan is to ‘remove unnecessary barriers to jobs, business and investment through a positive policy framework’. We are concerned that the undefined use of the term ‘undeveloped coast’ in the context of policy 15 is introducing such an unnecessary barrier to the delivery of Objective 9 which seeks to increase ‘renewable and low carbon energy production’.

• There is no evidence that the development of any type, or scale, of renewable energy facility would harm the natural beauty of these areas. REG Windpower works very hard to ensure that our development proposals, and operational sites, will have a minimal impact on the natural environment. The need to lessen the impact of human activity on the natural environment, particularly in respect of CO2 emissions and climate change, is one of the key drivers behind the urgent need to increase the installed capacity of renewable energy. We would highlight that many of these areas are not ‘natural’, they

are instead a reflection of human intervention, predominantly through farming, mining and fishing, over many generations.

Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

Policy 28: Infrastructure.


It is becoming increasingly apparent that one of the main constraints in respect of the deployment of renewable energy in Cornwall is the capacity of the electricity grid to accommodate such development. Western Power Distribution recently stated that, as result of recently approved renewable energy development, parts of its system "would be at the limit of the generation they can accommodate" and that "we have seen many large scale photovoltaic (PV) generation applications, as well as a few wind farms across the South West and particularly in Cornwall over the last few years. To connect further would therefore require extensive reinforcement of existing or building of new circuits, which can be quite expensive." Merlin Hyman of Regen SW, has confirmed this position by stating that "It is not a secret that the grid's capacity is the biggest constraining factor for the growth of solar energy. We are working hard with Western Power Distribution to ensure there is investment in reinforcing networks, otherwise the grid will be a major barrier to some renewable energy projects”. While the issue of grid capacity is recognised in the Cornwall Local Plan itself (para 2.62) it is unfortunate, given the strategic role being played by Cornwall Council, that the Cornwall Infrastructure Needs Assessment (dated 04.01.2013) appears to identify only £5M of funding to upgrade the existing distribution network west of Indian Queens to higher voltage between 2016 and 2020. It is considered that the existing distribution network will require a much higher level of investment in order for Cornwall to truly become a ‘green peninsula’ and support the installation of the major renewable energy infrastructure required. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies


Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies


Q4. Did you raise this issue earlier in the plan preparation process?

If yes, please specify at what stage: Q5. If your representation is seeking a change, do you wish to participate at the examination in public? No I do not wish to participate at the examination in public

Yes I wish to participate at the examination in public

If you require any assistance in completing this form or require any further explanation as to what is required please contact a member of the local planning team using the email address below or telephoning 01872 224283. Completed forms should be submitted: by e-mail to: [email protected] by post to: Cornwall Council Local Plans Team Carrick House St Clement Street Truro TR1 1EB Please submit any views to Cornwall Council using the above methods by 5:00pm on 22 April 2013.

Yes No

Next steps The representations received during this formal round of consultation will be reported to and considered by the Council. Any significant changes will be consulted on prior to consideration by the planning inspectorate, who will appoint an inspector to conduct an examination in public.

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Local Plan – Strategic Policies Pre-submission document representation form Please return to Cornwall Council by 5.00pm on 22 April 2013 Please complete a separate sheet for each representation you wish to make (All representations will become public) 1. Personal details.

2. Agent details (if applicable).

Name Michael Kelly Andrew Beard Organisation Amy Property

Developments Ltd. CSJ Planning Consultants

Address line 1 1 Host Street Address line 2 Address line 3 Address line 4 Bristol Postcode BS1 5BU Telephone number 0117 927 2224 Email address [email protected] Q1. Do you consider that the Local Plan meets the legal and procedural requirements? No Comment


Please specify the reasons below No, the Plan fails to meet the tests of soundness set out in NPPF, paragraph 182. It is not

positively prepared in that the strategy is not effective as the policies are too vague and

broad brush which does not give clear guidance and certainty to bring forward necessary

development in relation specifically to Policy PP9 (2).

The plan is not consistent with National Policy as it does not effectively promote the vitality

and viability of town centres with sufficient certainty and guidance to encourage new retail

development at St Blazey, which is badly needed to accompany future homes and jobs

growth and address current deficiencies of provision by just one Co‐op store.

No

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Accordingly the policy is considered unsound.

Q3. Please set out below any concerns you have with the Local Plan including any change(s) you consider necessary to address these concerns. You will need to say how this change will address the concerns and it would be helpful if you could put forward your suggested revised wording to any policy or text and any evidence to support the change. Please state which paragraph or policy your change refers to and specify the reasons below: Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

12.12 and BFL2 PP9 (2)

Policy PP9 (2) – St Blazey, Fowey and Lostwithiel CNA

The basis of this submission is that Policy PP9 (2) does not expressly support new retail

development to deliver a new town centre for St Blazey.

It deals only with employment ‘B’ Use Classes and housing and in efeftc a roll forward of the

traditional approach to employment land designations. A new town centre notation should

be included in the strategy vision, from which more detailed allocations and policies can

flow.

At paragraph 12.12 states that key community aspirations includes – the regeneration of St

Blazey town centre and the local economy – However, there is no ‘meat’ to any bones of the

policy. Emerging NCA work is identifying the local aspiration for new retail provision within

the town centre but the local plan is silent on detail or vision. In a depressed market,

promotion and support should be more specific to a wider economy base including retail as

well as offices and industrial for jobs.

Similarly Objective BLF2 dealing with economy and St Blazey town centre makes no

reference to new retail development in St Blazey. There needs to be more transformational

vision to deliver a new town centre for St Blazey with a new retail store and not just further

employment provision.

Particular Problems of the Draft Policy

The policy is too vague and relies solely on traditional employment for regeneration. The

former Ice Cream factory site off Middleway has an extant permission for 26,000 square foot

of B1, B2, B8 use with trade counters (references 10/00505 outline variation & 07/00419

Reserved Matters) but it is unviable to construct in the current market and there has been

no firm interest following 3 years of active marketing.

Is the approach of the LPA Consistent with national Planning Policy?

It does not actively promote town centre uses for St Blazey and promote growth as set out

in NPPF paragraph 23. It does not

Positively promote new retail growth at St Blazey,

Broadly identify the extent of the town centre,

Promote competitive town centres that provide customer choice and a diverse retail

offer and which reflects the individuality of town centres,

Allocate a range of suitable sites

Please set out any concerns and any changes considered necessary?

New retail development should be expressly supported (subject to detailed considerations in

general policies) at the centre of St Blazey around Middleway, Station ERoad and including

the former Ice Cream factory site.

A specific notation for St Blazey should be included in figure 15.

The general extent of the town centre of St Blazey, should cover the following key sites

identified below

Q4. Did you raise this issue earlier in the plan preparation process?

If yes, please specify at what stage: At all stages and also in the Regeneration Action Area Plan consultations. The St Blazey former Ice Cream factory site has been consistently promoted as a retail opportunity to deliver a new town centre for St Blazey.

YES

Q5. If your representation is seeking a change, do you wish to participate at the examination in public? No I do not wish to participate at the examination in public

Yes I wish to participate at the examination in public

YES

If you require any assistance in completing this form or require any further explanation as to what is required please contact a member of the local planning team using the email address below or telephoning 01872 224283. Completed forms should be submitted: by e-mail to: [email protected] by post to: Cornwall Council Local Plans Team Carrick House St Clement Street Truro TR1 1EB Please submit any views to Cornwall Council using the above methods by 5:00pm on 22 April 2013.


702 Dear Sir / Madam Please find attached before 5.00 p.m. today as required a completed representation form in relation to the Draft Pre Submission Local Plan and policy PP9 (2) regarding St Blazey. I represent a key landowner in St Blazey (Amy Property Development Ltd) and are very concerned that the new Local Plan vision is not more supportive and specific of new retail development around Middleway. A key site is the vacant former ice cream factory site which has a consent for B1/B2/B8 with trade counters along with adjoining land used by the showground industry. Given the new housing (900 homes) and 600 jobs, of which retail development could help deliver, a new town centre is widely supported. The town currently only has a single retail store (Co‐op) but the Local Plan is ‘silent’ giving no clear vision, leadership or direction to provide support and encouragement for the developer and market. The local plan should be clear in a strategy headline for St Blazey that – promotes a new competitive town centre providing further customer choice and a diverse retail offer reflecting the individuality of the town. This is an objective of NPPF paragraph 23. The area cannot rely just on a future of traditional B1, B2 and B8 employment as regeneration of the town centre but a mix of uses including retail, employment and housing. The former Ice Cream factory site ahs an extant permission for 26,000 square foot of employment use, but in the market it is unviable to construct and deliver based on the likely rental values. St Blazey currently lacks a range of services and there is scope for further new development such as: discount food store; food retail; small scale retail/employment units – the vision within the Local Plan should be promoting that, but as currently drafted it is very weak on any new opportunities for St Blazey Town Centre. The general statement to support St Blazey Town Centre regeneration is welcomed in 12.12 but we believe it should go further. Whilst a response might be that this will flow from other detailed future documents, it needs the policy / strategy hook now for this to be developed further in site allocations and the emerging neighbourhood plan. If you require any discussion, clarification etc. then please do not hesitate to contact me. We would welcome active dialogue and partnership to promote and drive forward the badly needed improvements for St Blazey town centre. St Blazey residents shouldn’t have to travel to St Austell for a range of services, but a new town centre appropriate in scale to the town should be actively promoted by the Council and the sites are available to bring it forward. It would be good to make real progress during 2013 in allowing that to happen. I would be grateful if you could acknowledge these representations as ‘duly made’.

Kind regards,

Andrew Beard BA(Hons), MRTPI Director CSJ Planning Consultants Ltd Chartered Town Planning Consultants 1 Host Street, Bristol BS1 5BU

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703

Miss Erica Uren

22nd April 2013

To whom it may concern,

Re: The Local Plan: 2012-2030 Strategic Policies pre-submission version.

As a young local Cornish person myself, I do not believe that this local plan is appropriate to the real needs of this area or respectful.

We should clearly and so obviously be using brown field sites and preserving green field sites for local food production and associated local employment. Sadly the draft document doesn't provide clear policy boundaries which leaves our high grade arable land open to being 'raped' by greedy house building companies who care nothing for this area or the people they are inadequately housing in 'toy town' estates, packing in as many houses into the smallest space imaginable. Building in St Austell because another part of the Duchy has need of supply does nothing to address the other area’s local needs nor is it sustainable.

Yours sincerely.

Erica Uren

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704 NAME___Lisa Schofield I believe this plan is unsustainable and will be damaging to Cornwall’s environment, economy and culture. Since 1960 Cornwall's population has grown by 60%. This rapid population growth has clearly not produced the economic benefits its supporters claim. In Cornwall planning application are three times above the average in Britain and 85% of all applications are approved compared to 75% in the rest of the country. This is growth for growth’s sake and cannot be justified. The current plans proposed by Cornwall Council mean we will have to build the equivalent of five new Truros in the next 20 years! This trend means that Cornwall's population will approach one million by the end of this century. This is too high a price to pay and is unnecessary. CoSERG has produced fact-based evidence, based on analysis of recent and current growth trends that shows the housing figure over the period of the plan should only be 29,000. We cannot justify building houses on Greenfield sites, this must stop. PLEASE NOTE MY RESPONSE WHICH IS FOR 29,000 HOUSES FOR CORNWALL OVER THE NEXT 20 YEARS.

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nature’s voice

South West England Keble House Southernhay Gardens Exeter Devon EX1 1NT

Tel 01392 432691 Fax 01392 453750

www.rspb.org.uk

Patron: Her Majesty the Queen Chairman of Council: Professor Steve Ormerod, FIEEM President: Kate Humble Chief Executive: Dr Mike Clarke

The Royal Society for the Protection of Birds (RSPB) is a registered charity: England and Wales no. 207076, Scotland no. SC037654

Cornwall Council

Strategic Policy Team

Carrick House

St Clement Street

Truro TR1 1EB

Cornwall

22 April 2013

Dear Sir or Madam

Cornwall Local Plan Strategic Policies 2010-2030. Pre-submission document March 2013 ___________________________________________________________________________________

INTRODUCTION

Thank you for seeking our views on the above document (‘the plan’). We have two main

interests in the plan:

1. The potential impacts of draft policies on Cornwall’s nature conservation assets,

especially Natura 2000 and Ramsar sites, nationally designated Sites of Special Scientific

Interest (SSSIs), County Wildlife Sites (CWS) and non-designated coastal and maritime

BAP habitats which are important for priority bird species.

This includes the Natura 2000 network of sites consisting of the Tamar Estuaries Complex

Special Protection Area (SPA); Marazion Marsh SPA; The Lizard Special Area of

Conservation (SAC); Breney Common & Goss & Tregoss Moors SAC; Fal & Helford SAC;

and the Isles of Scilly Ramsar site.

It also includes the network of non-designated Important Bird Areas (IBAs) consisting of

Bodmin Moor IBA; the South Cornwall Coast IBA; the West Penwith Coast & Moors IBA;

and the Isles of Scilly IBA.

It also includes the Hayle Estuary & Carrick Gladden SSSI, part of which is owned and

managed by the RSPB as a nature reserve, and the county’s extensive areas of coastal

grasslands and heathlands which are important for nationally rare bird species such as

chough.

2. The potential for the plan to assist in the enhancement, restoration, re-creation and

monitoring of priority habitats within the Cornwall ecological network and the protection

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and recovery of priority species populations. The underlying principles of landscape-

scale restoration for nature conservation are set out in the Natural Environment White

Paper - The Natural Choice: securing the value of nature 2011 and carried forward into the

National Planning Policy Framework 2012 (NPPF) at para. 117 – ‘to minimise impacts on

biodiversity and geodiversity, planning policies should plan for biodiversity at a

landscape-scale across local authority boundaries.’

ASSESSMENT OF PLAN IMPACTS ON CORNWALL’S NATURE CONSERVATION

ASSETS

In our view, the assessment of the likely impacts of the plan on key nature conservation sites and

species is inadequate for the following reasons:

Whilst we recognise the strategic nature of the plan, its impacts depend critically on

policies and proposals contained in other planning documents, some of which have not

yet been produced (para 1.1). These include Neighbourhood Plans, Supplementary

Planning Documents (SPD) and ‘Strategic Frameworks’ for key coastal CNAs. The latter,

whilst critical in relation to coastal sites sensitive to human pressure, such as the Tamar

Estuaries Complex SPA, the Fal & Helford SAC and the South Cornwall Coast IBA, have

yet to be developed and agreed with key statutory bodies and other stakeholders.

The HRA inadequately assesses the impacts on a number of Natura 2000 and Ramsar

sites. It is acknowledged in the HRA that there is virtually no baseline data on human

disturbance in and around sensitive sites. Consequently, the filtering process to screen

out potentially sensitive sites is superficial and inadequate. We strongly question the

conclusions of the HRA regarding current and potential levels of human impacts likely to

arise from the plan on sites such as the Tamar Estuaries Complex SPA, the Lizard SAC

and the Fal & Helford SAC.

Despite the authors of the HRA citing research which shows that key species groups such

as marine waterbirds may be sensitive to disturbance, there is no attempt to assess

potential impacts arising from the plan on the South Cornwall IBA. This site supports

nationally important numbers of some species, and is likely to become a maritime SPA in

the near future.

We do not feel comfortable with the analysis of potential impacts presented in the HRA

and disagree with its conclusions. We are not assured that the council has fully

considered the potential impacts of its policies and proposals on the Natura 2000 and

Ramsar site network and we therefore OBJECT to the conclusions of the HRA.

VISION & OBJECTIVES

We welcome and SUPPORT the intention of the council through the plan to achieve a leading

position in sustainable living (para 1.14).

We welcome and SUPPORT the intention of the council through the plan to protect the county’s

special assets (para. 1.15) and to take environmental issues into account in achieving this aim

(para 1.17). However, it is unclear to us how the council can be sure that it can achieve this given

the shortcomings of the HRA and the proposed Monitoring Framework (see below).

This plan is explicitly pro-growth. However, in our view, the balance of emphasis within the

plan is far too much on economic development whilst underplaying the importance of the

county’s nature conservation assets. For example, under ‘Cornwall in context’ there is no

mention of the county’s exceptional nature conservation sites or species. Other examples are

highlighted below. We therefore OBJECT to the balance of the plan and the lack of sufficient

emphasis given to the importance of Cornwall’s natural environment.

Cornwall contains many sites and places that are special for their biodiversity. Protection of these

sites should be a central aim of the plan. Many of the species and habitats on these sites are

vulnerable to a range of impacts including development, climate change, intensification of

agriculture and pollution. Therefore, in order to ‘protect what we know is special’ it is crucial to

plan for biodiversity at a landscape scale by creating a coherent and resilient ecological network, in

accordance with the NPPF at para 117.

The language within the plan used to describe the county’s environmental assets is inconsistent

and at times unclear. There is frequent switching between terms such as ‘biodiversity’, ‘wildlife’,

‘natural assets’ and ‘natural environment’, which confuses the policies. It is unclear whether

nature conservation assets are at times included under the general descriptors of ‘landscape’,

‘local natural character’ or ‘environment’. The plan would be much clearer if it referred to nature

conservation specifically throughout the plan, keeping it separate from other descriptors.

Examples are again highlighted below. Terms such as green infrastructure also need to be

defined early on in the document or in a glossary, and the relationship between green

infrastructure and the wider Cornwall ecological network needs to be described clearly. We

therefore OBJECT to the lack of clarity of key terms in the plan.

Objective 10b is far from clear and should be re-worded. It reads as ‘Maintaining and enhancing

….environmental stewardship for our ecosystems services network for….wildlife.’ This is poor

English and unclear. Further:

It is not clear what ‘environmental stewardship’ means in this context.

‘Maintaining and enhancing an effective network of open space and environmental

stewardship...’ does not necessarily address the following key requirements of the

National Planning Policy Framework:

o Providing net gains in biodiversity (para. 109).

o Planning positively for the creation, protection, enhancement and management of

coherent ecological networks that are more resilient to current and future

pressures (paras. 109 & 114).

o Planning for biodiversity at a landscape scale (para. 117).

These requirements of the NPPF should be highlighted more explicitly within the

objectives of the plan. We therefore OBJECT to the current wording of this objective. Sustainable development Policy 1 Presumption in favour of sustainable development

The key ecological principle within the concept of sustainability is the need for human societies

to live within their environmental limits. A key test of this within the plan is whether its policies

protect the county’s nature conservation capital from net loss, whilst sustaining the species

populations for which the sites are recognised, and restoring , enhancing and reconnecting

isolated key sites. This should be made clear in the document, and should form an explicit test of

the sustainability of the plan. We OBJECT to the lack of clarity and lack of sufficient nature

conservation indicators of sustainable development in the plan.

Policy 1a is totally inadequate in relation to the hierarchy of designated nature conservation sites.

In particular the simple ‘benefits test’ set out in the policy is not in accordance with the stringent

tests set out in The Conservation of Habitats& Species Regulations 2010 for Natura 2000 sites.

There are specific tests regarding ‘imperative reasons of overriding public interest’, or, for a

priority natural habitat types or a priority species, ‘reasons relating to human health, public

safety or beneficial consequences of primary importance to the environment’. We therefore

OBJECT to this policy.

We wish to see the council set out very clearly the hierarchy of tests it seeks to require in relation

to Natura 2000 sites, nationally important SSSIs, County Wildlife Sites and priority species, in a

revised policy P23 – the Natural Environment Policy (see below).

Spatial strategy

We are concerned that the stated overall aim of the Spatial Strategy is to promote economic growth

in Cornwall (para 1.19). This is an unnecessarily focus on just one function of the plan and does

not accord with the NPPF:

1. Having an overall aim of supporting economic growth is contrary to the principles of

sustainable development since it does not reflect the requirement to improve social and

environmental conditions in the area as well. The overall aim of the plan should address the

social and environmental aspects of sustainable development as well as the economic

aspects.

2. A key aim of the plan must be to ensure sustainable economic growth; that is growth

which can be sustained within the environmental limits of the county and global

environment. It does not mean growth that can be sustained without regard to its

external impacts.

3. Para 1.22 states that the aim of economic growth is ‘underpinned’ by the need to protect

‘our environment’. The words ‘underpinned’ and ‘our environment’ need to be explained

more fully.

4. The importance of maintaining and enhance Cornwall’s ecological network of protected

and unprotected nature conservation sites should be highlighted as a priority aim in the

Spatial Plan. The Spatial Strategy should also refer to the need for the plan to identify and

map components of local ecological networks, including the hierarchy of international,

national and locally designated sites of importance for biodiversity, wildlife corridors and

stepping stones that connect them and areas identified by local partnerships for habitat

restoration and recreation (NPPF, para. 117). This is partially achieved in maps 4 and 5,

but the more detailed mapping of local wildlife corridors at the CNA level also needs to

be agreed and mapped in a supporting SPD and referenced in the plan.

5. We therefore OBJECT to the overall aim of the Spatial Strategy.

Policy 2 – Key targets and Spatial Strategy

We welcome and SUPPORT policy 2.3 and support the intention to deliver renewable and low

carbon energies, increase energy efficiency and minimise resource consumption through onshore

technologies, provided these do not adversely impact important nature conservation sites and

species.

We welcome and SUPPORT the intention in policy 2.5 to positively manage new development

through the protection [and] enhancement of environmental assets and adaptation to climate

change.

However, ‘mitigation of environmental assets’ is not appropriate wording: mitigation should

relate to any adverse effects on the environmental assets, rather than mitigation of the

environmental assets themselves. We therefore OBJECT to the wording of this policy.

The RSPB SUPPORTS the objective of ‘protecting and enhancing ... habitats, particularly in areas

defined as Heritage Coast, Areas of Outstanding Natural Beauty and Sites of Special Scientific

Interest’. Policy 2.6 is however unclear and seems to imply a commitment only to protect habitats

on the undeveloped coast, and only SSSIs amongst the suite of nature conservation designations.

Whilst the coast is a vitally important component of Cornwall’s ecological network, many

priority habitats and sites designated for their nature conservation value are located away from

the coast, for example, on Bodmin Moor and in the China Clay area near St Austell. This policy

needs rewording to address these issues. We therefore OBJECT to the policy in its current form.

The Cornwall Biodiversity Action Plan identifies 12 Priority Project Areas for the period 2010-

2015:

All of the Coast

Biotope Mapping

Bodmin Moor Mires and Headwaters

Camborne Pool Illogan and Redruth

China Clay Area

Coast to Coast

Cornwall’s Super Green Spine

Culm

Linking the Lizard

Plymouth GI and Tamar Valley Woods

Truro Development – Growth Point

Wild Penwith

The Cornwall Local Plan should incorporate all designated nature conservation sites and these

twelve Priority Areas into the objective of protecting and enhancing habitats. In particular, the

China Clay Area should be identified as a priority for habitat enhancement as it provides a

unique opportunity for the creation of new heathland habitat through the restoration of mineral

sites. We therefore OBJECT to the omission of these 12 Priority Project Areas from the plan.

Policy 2 should also explicitly seek a net-gain in biodiversity and the creation of a coherent and

resilient ecological network, in line with the NPPF (para. 109 and 104).

GENERAL POLICIES

Jobs and Skills

Policy 5.2 refers to the plan’s intention to support growth of ports and harbours. It is worth

highlighting the potential constraints on the future expansion of Falmouth port facilities due to

the presence of the internationally important maerl beds in the Fal & Helford SAC. This remains

one of the key conservation issues in Cornwall. We OBJECT to the lack of acknowledgement in

the plan of this important issue. Housing

Para 2.46 refers to the central challenge of how housing development will respond to the

character of the Cornish landscape. It is unclear whether the word ‘landscape’ is used as a proxy

for other environmental features as well. This challenge should also include potential impacts on

the county’s nature conservation assets, and we wish to see this explicitly referred to in the text

and policy. We therefore OBJECT to the wording of this text.

Para 2.52 Development Standards refers to ‘suitable treatment of natural assets’ in relation to

design and layout standards of new developments. Again, this is too vague and we wish to see

explicit reference to international, national and local nature conservation sites and priority BAP

habitats and species, and to a clear hierarchy of protection for the different nature conservation

designations. We therefore OBJECT to the wording of this text.

Design

For larger developments there may be opportunity to create local nature reserves. This should be

highlighted in the list of potential new facilities in policy 3.3.

Development Standards

In relation to potential impacts on important nature conservation features policy 14 is

inadequate, referring only to the need to ‘avoid adverse impacts’ on unspecified features. We

therefore OBJECT to the wording of this policy in its current form.

This policy should also include a commitment by the council to require developers to

implements and fund ongoing management of Sustainable Urban Drainage Schemes as the

default drainage requirement. We therefore OBJECT to the omission of references to SUDS and a

commitment by the council to require their installation and maintenance as a condition of new

development allocations.

Policy 14 should include a requirement for development to provide a net gain in biodiversity,

both within the built environment and adjacent areas which may be suitable for habitat creation,

restoration or enhancement, in line with the NPPF (paras. 9 & 109). This could be achieved

through reference to policy 23 the Natural Environment. We OBJECT to this policy in its current

form.

Exeter City Council Residential Design Supplementary Planning Document - Extract of Biodiversity

Requirements which was adopted in September 2010 provides a useful guide to sorts of measures

that could enhance new development for biodiversity. For example, nesting and roosting boxes

should be built as part of the fabric of the building for building-reliant birds (e.g. swifts,

swallows and house martins) and bats and birds associated with urban areas (e.g. house

sparrows and starlings). As a guideline, a minimum overall average of built in nest/roost site per

residential unit should be provided. For multiple-dwelling buildings or those over 9m in height

multiple swift nest boxes should be provided for colony-forming species. We OBJECT to the lack

of suitable policies which would require new development to incorporate features for building-

reliant birds and bats.

The amount of priority BAP habitat within or adjacent to a development should be significantly

greater than the amount of priority habitat that existed prior to development. This net gain in

biodiversity should be provided in the context of contributing to a coherent and resilient

ecological network, ie when creating new or additional habitat, the developer should consider

how this habitat helps to buffer, extend or link existing habitats in the local area.

Policy 15 - Renewable and Low Carbon Energy

This policy gives no recognition to the potential adverse impacts through disturbance and

collision risk of insensitively located wind turbines on birds and other wildlife, notably bats.

There are a number of potentially sensitive areas in Cornwall where it would be inappropriate to

consent wind turbines. These areas should be agreed, mapped and adopted by the council as a

supplementary planning document. It is unclear whether the ‘broad landscape strategy’ referred

to at para 2.60 fulfils this purpose (especially given the document title refers to ‘landscape’ rather

than nature conservation). This is likely to be a critical document which needs to be assessed

through the HRA process. Again, we are concerned that the text at para 2.60 refers only to

potential landscape impacts and not to potential impacts on priority nature conservation sites,

habitats and species. We therefore OBJECT to the current wording of this policy.

MINERALS

Mineral site restoration provides a unique opportunity to make a significant contribution to

achieving national biodiversity targets through the creation of priority habitat. A report by the

RSPB in 20061 showed that mineral site restoration alone could achieve the national habitat

creation targets for nine priority habitats. In Cornwall, this is particularly relevant to the

restoration of mineral sites in the China Clay Area, which could make a significant contribution

to local and national habitat creation targets for lowland heathland.

As well as ‘being of a scale sensitive to any landscape designations’, any new mineral

development should also be of a scale sensitive to any nature conservation designations. In order

to comply with the requirements of the NPPF (paras. 14, 113, 118 & 119), policy 18 should also

explicitly state that there should be no adverse effect on international and national nature

conservation designations or irreplaceable habitats, including ancient woodland. For sites

designated for local nature conservation interest and for priority habitat lying outside of

designated sites, mineral development should follow the mitigation hierarchy (avoid – mitigate –

compensate). We therefore OBJECT to policy 18 in its current form.

In order to ensure that mineral sites in Cornwall help to achieve habitat creation potential, and to

comply with the requirements of the NPPF (paras. 9, 109, 114 & 117), policy 18 should:

1 Nature After Minerals: how mineral site restoration can benefit people and wildlife, RSPB / MIRO, 2006

Explicitly require mineral site restoration to provide a net gain in biodiversity that

contributes to the creation of a coherent and resilient ecological network. The presence of

adjacent habitats and designated sites and opportunities to strengthen or create ecological

networks should inform restoration proposals.

Where a choice exists, restoration to more difficult habitats should be encouraged. i.e.

opportunities to create some habitats (e.g. heathland) will be rare compared to others (e.g.

broadleaved woodland).

Require mineral planning proposals to be specific about which habitat will be restored on

particular sites (with details listed in a Supplementary Planning Document).

Include a statement against a general presumption to restore a mineral site to agriculture

on the best and most versatile agricultural land, in line with NPPF para 143.

Not necessarily discourage the restoration of mineral sites to ‘open water’ due to the

associated risks of bird-strike, when mineral sites are within 13km ‘safeguarding zones’

of airports / airfields. There are many examples of restored mineral sites within these

safeguarding zones where good design of wetland habitat has reduced the area of open

water and minimised the risk of bird strike.

Policy 18.3 refers only to landscape designations in assessing the suitability of new mineral

development. This is not sufficient. Nature conservation designations should also be used in

determining the suitability or otherwise of new mineral proposals.

We therefore OBJECT to this policy on the grounds set out above.

We SUPPORT the intention set out in policy 18.6 to require effective reclamation at the earliest

opportunity, where this would contribute to and enhance the natural environment, ecosystem

services and Cornwall ecological network.

Policy 22 - Best use of land and existing buildings

There needs to be some flexibility in this policy to allow development away from areas of low

agricultural value where a site has high nature conservation value, since many such sites occur

on low grade agricultural land. We wish to see a further clause (e.) added to this effect and

therefore OBJECT to this policy in its present form.

CORNWALL’S NATURAL ENVIRONMENT

Introduction

We welcome and SUPPORT the statement at para 2.88 about the importance of Cornwall’s

natural environment, and that is must remain at the heart of the county’s distinctiveness. We

welcome and SUPPORT recognition of the importance of the natural environment to Cornwall’s

economy and quality of life.

We also welcome and SUPPORT recognition at para 2.88 that the natural environment is not, and

should not be, a barrier to the plan, and that careful stewardship of Cornwall’s natural assets

requires that economic growth does not undermine this important asset base.

Responsibility for safeguarding Cornwall’s natural environment

The wording of policy 23 - Natural Environment is unclear at critical points. The text seems to

suggest that responsibility for safeguarding, enhancing and managing the county’s nature

conservation assets is solely developer-driven, and in particular that any potential habitat gains

that will be delivered during the plan period must come solely through conditioning of planning

consents. We OBJECT to the wording of this policy and wish to see explicit reference to the

duties and responsibilities of the council in relation to the protection, enhancement, restoration

and re-creation of critical habitats with the Cornwall ecological network.

It is a role of the plan to set out specific policies that:

Contribute to the conservation and enhancement of species populations in the wider

environment (i.e. outside Natura 2000 sites), in order to help deliver the overall objectives

of the Birds and Habitats Directives.

Require assessment by the council of the existing Cornwall ecological network under

current and future climate conditions, working with Local Nature Partnerships (LNPs)

where appropriate. The plan should also support and specify actions for the protection,

enhancement and management of priority habitats and recovery of priority species

populations within this network, in line with the NPPF (paras. 114 & 117). The plan

should also explicitly seek the Cornwall ecological network to be coherent and resilient,

in line with the NPPF (para. 109).

Ensure that other strategies support the creation of ecological networks and where possible

exploit win-win opportunities (e.g. flood management by creating wetlands or green

roofs on new housing to support urban ecological networks).

Consider how site allocations can best enhance these networks.

We do not believe that the plan in its current form, and as expressed mainly through policy 23 –

Natural Environment sets these elements out clearly. We therefore OBJECT to policy 23 in its

current form, and for the further reasons set out below.

Identifying important sites

Paras 2.29 and 2.94 attempt to list the key designated sites within the county and this is

complimented by fig 4. A definitive map showing all key nature conservation sites, including

SSSIs, Important Bird Areas (IBAs) and County Wildlife Sites should be referenced in the plan,

and should be adopted by the council as a supplementary planning document. Figure 4 should

also show all Cornwall’s SSSIs.

Each CNA should include or refer to a map showing the Cornwall ecological network and the

importance of the local ecological network within the CNA as a component of the countywide

network. The CNA ecological network map should include all existing and proposed green

infrastructure around settlements and sites identified through the plan as being important for

buffering, expanding or linking elements of the ecological network. These maps should form

SPDs to the strategic county plan. We OBJECT to the omission of these local CNA maps.

Safeguarding important sites

The plan should include or refer to background papers setting out the full scope of issues

associated with the natural environment resulting from future development. We OBJECT to the

lack of reference to key background papers setting out the main issues facing key sites and

species in the county.

Human disturbance is a significant theme in the HRA and measures to address disturbance,

especially that likely to arise through increased recreational pressure, and particularly with

regard coastal sites, need to be included in the plan. The management of increased recreational

pressure as a result of population growth in Cornwall will be a particular issue for Natura 2000

sites and SSSIs, including offshore areas of high nature conservation value.

The plan needs to be informed through the production of area based recreational strategies for

each CNA, and the identification of the Strategic Areas of Green Space (SANGs) where

appropriate. We OBJECT to the omission of any reference to these.

We wish to see inclusion of a specific policy on disturbance:

‚All development proposals shall incorporate appropriate measures to avoid and reduce

disturbance of sensitive wildlife species and habitats throughout the lifetime of the development.

Development likely to increase recreational pressure on Natura 2000 and Ramsar sites, Sites of

Special Scientific Interest, County Wildlife Sites or the Cornwall ecological network, will be

required to deliver an appropriate level of mitigation to offset any potential impacts.

Provision of an appropriate areas of Suitable Accessible Natural Greenspace (SANG) to deter

public use of Natura 2000 and Ramsar sites (SPAs and SACs) will only be acceptable in

exceptional circumstances. Such measures shall be secured through reasonable and

proportionate planning obligations and agreements.‛

We welcome and SUPPORT recognition at para 2.97 that the undeveloped cost will be protected

from development not normally requiring a coastal location.

Safeguarding criteria

We welcome and SUPPORT the intention to require developers to protect and enhance

Cornwall’s natural environment.

The ‘presumption in favour of sustainable development’ specifically excludes sites protected

under the Birds and Habitats Directives, SSSIs (NPPF, para. 14 & footnote 9). This is an important

context for policy 23 and should be included in the plan text. We OBJECT to its omission.

Policy 23.3a – this is a weak policy as currently worded and does not fully reflect national policy.

The phrase ‘safeguarded from inappropriate development’ is vague and suggests that the council

will ‘safeguard’ all such sites from development without any criteria. The plan should set out

clear, criteria-based policies against which proposals for any development on or affecting protected

nature conservation sites will be judged. Distinctions should be made between the hierarchy of

international, national and locally designated sites, so that protection is commensurate with their

status and gives appropriate weight to their importance and contribution that they make to the

wider Cornwall ecological network (NPPF para. 113). We OBJECT to the absence of clear criteria-

based policies for Cornwall’s protected sites.

The plan should include a specific policy for protecting UK BAP species within the county,

including S.41 species and habitats of ‘principal importance’ under Section 41 of the Natural

Environment and Rural Communities Act 2006 (NERC). The S41 list is used to guide local

authorities, in implementing their duty under section 40 of the NERC Act 2006, to have regard to

the conservation of biodiversity in England, when carrying out their normal functions. We

OBJECT to this omission.

We SUPPORT the use of buffer areas to help safeguard designated nature conservation sites

from inappropriate development (policy 23.3a).

We SUPPORT the requirement to ensure that development conserves and enhances BAP habitats

and species; and that developers ensure firstly no net loss of existing biodiversity, and secondly

enable net gain in biodiversity through sensitive design, avoidance of special features and

appropriate mitigation (policies 23b & c).

Mitigation , compensation & no net loss

We welcome and SUPPORT the intention to require developers to ensure no net loss of existing

biodiversity and enable a net gain in biodiversity by designing in biodiversity, and to ensure that

any unavoidable impacts are appropriately mitigated and/or compensated for.

The plan should require developers to avoid adverse effects where possible and mitigate on site

where adverse effects are unavoidable. The plan should also require that off-site measures

should be carried out only as a last resort, where mitigation does not adequately reduce the

adverse effects. Compensation would normally be required under The Conservation of Habitats

& Species Regulations 2012 where a development proposal is likely to have an adverse impact on

a Natura 2000 site. If the adverse effects cannot be adequately mitigated or compensated for, then

the development should not be permitted. We feel that the plan should be clearer on these terms

and therefore OBJECT to the lack of clarity in the current wording.

We welcome and SUPPORT the intention to require developers to make provision for the

management of habitats and species within their sites and to require them to use up-to-date

evidence and management plans (policy 23a).

Enhancing, restoring & creating parts of the Cornwall ecological network

The RSPB SUPPORTS the inclusion of the figure 5 map and the reference to it within policy 23.

Potentially, the greatest opportunity for development to contribute to the vision of the South

West Nature Map is the creation of lowland heathland through mineral site restoration in the

China Clay Area and on the Lizard Peninsula. We wish this to be highlighted in the plan.

To complement figure 5, it would be useful for the plan to include an additional map showing

the Priority Project Areas identified in the Cornwall Biodiversity Action Plan and the RSPB’s

Cornwall Coast Futurescape. We OBJECT to their omission from the plan.

Policy 23.d recognises the importance of the SW Regional Nature Map in providing an important

context for reinforcing and developing Cornwall’s ecological network. However, recognition by

the council is insufficient - as highlighted above, the plan must support and specify actions the

protection, enhancement and management of priority habitats and recovery of priority species

populations within this network, in line with the NPPF (paras. 114 & 117).We therefore OBJECT

to the current wording of this policy.

Policy 25 - Green Infrastructure

We welcome and SUPPORT this policy, especially the intention to ensure that development

proposals retain and enhance ecological corridors, and that these contribute to the county’s

Strategic Environmental Infrastructure Network; provide buffers to high value natural spaces;

and restore and enhance connectivity for nature and people.

We welcome and SUPPORT in principle the council’s strategic framework for future planning

and delivery of green infrastructure in Cornwall (para. 2.106).

Policy 28 Infrastructure

We welcome and SUPPORT the council’s intention to use CIL to fund and support the county’s

green infrastructure. We also agree that it makes sense to reinvest biodiversity offsetting

payments in the county wherever possible.

COMMUNITY NETWORK AREAS

The RSPB strongly recommends that each CNA has a policy that protects, conserves, and

enhances wildlife in line with policy G.

P1 West Penwith Community Network Area:

We SUPPORT objective 5 on the environment and the intention to maintain green infrastructure

(para 4.21). There needs to be a clear reference to the protection and enhancement of the

Marazion Marsh SPA and associated undeveloped floodplain, the undeveloped coastal strip, the

West Penwith Moors and important species such as chough. We OBJECT to the omission of a

statement to this effect.

PP2 Hayle and St Ives Community Network Area:

We welcome and SUPPORT recognition of the need to protect the outstanding natural

environment of the area. There needs to be a clear reference for the need to support the

protection and enhancement of the Hayle Estuary and Carrick Gladden SSSI, RSPB nature

reserve and the undeveloped coastline of the Towans and floodplains. This is an important

recreational and economic asset valued by local people and visitors alike. The CNA should

specifically seek to support and protect this important asset alongside historic and other features.

With the anticipated level of growth in this area additional green infrastructure (SANGs) will

need to be considered within these new developments to offset recreational pressures on these

sensitive sites. We OBJECT to the omission of statements in the plan to this effect.

PP3 Helston and the Lizard Community Network Area:

We welcome and SUPPORT recognition of the need to ensure development is sensitive to the

natural environment of the area. Some of these key natural assets should be listed including the

Lizard SAC, and critical species such as breeding Cornish chough, which has its centre of

distribution still on the Lizard. We OBJECT to the omission of a statement to this effect.

PP4 Camborne, Pool and Redruth Community Network

This policy should include a reference to the need to protect and enhance the green infrastructure

network in this CNA in order to reduce the potential effects of increased recreational pressure on

the coast. We OBJECT to this omission.

PP5 Falmouth and Penryn Community Network Area:

Objectives 5 & 7 – this CNA, along with PP6 Truro & Roseland, lies immediately adjacent to the

South Cornwall Coast IBA, an important nearshore area for wintering waterbirds. It is essential

that the ‘strategic framework’ mentioned under objective 7 (and objective 9 for PPR6) is agreed

with key stakeholders and implemented before any significant recreational development takes

place within the two CNAs. We therefore OBJECT to the lack of reference to this requirement.

Para 8.2 refers to Penryn and Falmouth Docks and their importance in the economic life of the

CNA. The text and policy needs to specifically mention that any growth needs to support the

management, protection and enhancement of protected sites, especially the Fal and Helford SAC

and the South Cornwall IBA, and the provision of green infrastructure particularly in relation to

managing increases in recreational pressure on these sensitive sites. It is essential that any

strategic growth opportunities are assessed within the environmental constraints of the Fal &

Helford SAC and the South Cornwall IBA and that the proposed strategic framework mentioned

under objective 7.

We therefore OBJECT to the lack of reference to these requirements in the plan.

PP6 Truro and Roseland Community Network Area:

Objective 9 sets out the need for a ‘strategic framework’ to balance economic and recreational

pressures with potential impacts on the marine environment. There is no reference to the South

Cornwall Coast IBA in the CNA or the reasons for its importance and sensitivity to human

disturbance.

The CNA needs to specifically mention that any growth needs to support the management,

protection and enhancement of protected sites such as the South Cornwall Coast IBA, and the

provision of green infrastructure particularly in relation to managing increases in recreational

pressure on sensitive nature conservation sites will need to be addressed.


PP9 - St Austell and Mevagissey; China Clay; St Blazey, Fowey and Lostwithiel CNAs

Of all the Community Network Areas (CNAs) in Cornwall, the China Clay CNA probably

provides the greatest potential for development to make a significant contribution towards

achieving local and national biodiversity targets and contributing to improving the coherence

and resilience of Cornwall’s ecological network. This contribution would primarily be through

the creation of priority habitats, especially lowland heathland on restored mineral sites, as

outlined in the China Clay Biodiversity Visioning document produced by the Cornwall Biodiversity

Initiative in 2009.

Reference therefore should be made in the plan to the importance of brown field sites for wildlife

and the significant potential in the China Clay Area for restoring and creating priority BAP

heathland and woodland habitats at a landscape scale. It is also important to acknowledge the

importance of protecting the undeveloped coast.


protection and enhancement of protected sites such as the South Cornwall Coast IBA, and the

provision of green infrastructure particularly in relation to managing increases in recreational

pressure on sensitive nature conservation sites will need to be addressed.

We therefore OBJECT to the omission of statements within the policy and text to this effect.

The RSPB SUPPORTS the objective to ‘conserve heritage assets, including ... nature conservation

sites and enhancement of the local environment (in particular emerging opportunities as a result

of restoring china clay workings)’.

PP17 Cornwall Gateway CNA

The potential impacts (including the in-combination effects of the Plymouth Core Strategy) on

the Tamar Estuaries Complex SPA and Plymouth Sound & Estuaries SAC will need to be

assessed and considered when determining the level of growth at Saltash.


protection and enhancement of both Natura 2000 sites, and the provision of green infrastructure

particularly in relation to managing increases in recreational pressure on sensitive nature

conservation sites will need to be addressed.


MONITORING FRAMEWORK

We fully support the need for the council to monitor the impacts of the plan on the county’s

nature conservation asset base, as required by the NPPF (para. 117). In order to assess the

sustainability of the plan, the council will need:

A thorough understanding of the nature conservation resource of the county.

A thorough understanding of the conservation potential and priority areas for habitats re-

creation and enhancement.

To identify a suitable range of biodiversity indicators to monitor.

To be able to accurately monitor any changes that occur over the lifetime of the plan.

These factors should determine the content of the monitoring programme in relation to the

county’s nature conservation asset base.

We welcome and SUPPORT the intention to monitor changes in:

The area of designated sites of international, national, regional, subregional and local

significance, although it is unclear what regional and sub-regional significance means in

the context of the plan.

The area of habitat to ensure no net loss across Cornwall’s ecological network.

The amount of biodiversity habitat gained through mitigation through 106 agreements.

The net increase in current levels of biodiversity habitat through the creation of: (i) new

Wildlife Corridors and (ii) new Local Wildlife Sites

We welcome the intention to monitor the future impact of planned development on international

nature conservation sites (para 2.93), although we wish to see this extended to all statutory and

non-statutory sites, including SSSIs and County Wildife Sites.

Monitoring the changes in the area of land designated for nature conservation will not provide

sufficient information on any changes over the plan period, and the plan should set out how the

council intends to monitor other key parameters including habitat condition and populations of

key species.

Similarly, the plan should set out the council’s plans for assessing current levels of human

disturbance on key sites, notably the Fal & Helford SAC and the South Cornwall Coast IBA. We

note the comment at para 4.2.25 in the HRA that the council is committed to improving this

situation and obtaining baseline visitor data for all relevant sites.

By implication the monitoring proposed at para 2.93 would provide a ‘cumulative assessment

register’, which we welcome, and would help expedite more quickly decisions on development

proposals which may have potential adverse impacts on international sites.

We OBJECT to the Monitoring Framework in its current form for the reasons set out above.

Cornwall’s natural environment is one of its biggest assets. This plan needs to ensure that this

asset remains for those in the future and with appropriate planning this can be achieved. We

look forward to working with Cornwall Council to achieve to their ambition to put Cornwall in a

‚leading position in sustainable living‛.

Yours faithfully

Paul St Pierre

RSPB Cornwall Conservation Officer

706

NAME_ Graham Warren

PLEASE NOTE MY OBJECTIONS TO THE LOCAL PLAN

I believe this plan is unsustainable and will be damaging to Cornwall’s environment, economy and culture. Since 1960 Cornwall's population has grown by 60%. This rapid population growth has clearly not produced the economic benefits its supporters claim. In Cornwall planning application are three times above the average in Britain and 85% of all applications are approved compared to 75% in the rest of the country. This is growth for growth’s sake and cannot be justified. The current plans proposed by Cornwall Council mean we will have to build the equivalent of five new Truros in the next 20 years! This trend means that Cornwall's population will approach one million by the end of this century. This is too high a price to pay and is unnecessary. CoSERG has produced fact-based evidence, based on analysis of recent and current growth trends that shows the housing figure over the period of the plan should only be 29,000. We cannot justify building houses on Greenfield sites this must stop.

PLEASE NOTE MY RESPONSE WHICH IS FOR 29,000 HOUSES FOR CORNWALL OVER THE NEXT 20 YEARS.

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706

707

RESPONSE TO LOCAL PLAN

Peter Malindine

PLEASE NOTE MY OBJECTIONS TO THE LOCAL PLAN

I believe this plan is unsustainable and will be damaging to Cornwall’s environment, economy and culture. Since 1960 Cornwall's population has grown by 60%. This rapid population growth has clearly not produced the economic benefits its supporters claim. In Cornwall planning application are three times above the average in Britain and 85% of all applications are approved compared to 75% in the rest of the country. This is growth for growth’s sake and cannot be justified. The current plans proposed by Cornwall Council mean we will have to build the equivalent of five new Truros in the next 20 years! This trend means that Cornwall's population will approach one million by the end of this century. This is too high a price to pay and is unnecessary. CoSERG has produced fact-based evidence, based on analysis of recent and current growth trends that shows the housing figure over the period of the plan should only be 29,000. We cannot justify building houses on Greenfield sites this must stop.

PLEASE NOTE MY RESPONSE WHICH IS FOR 29,000 HOUSES FOR CORNWALL OVER THE NEXT 20 YEARS.

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707

708 Dear Paul, I know you have had several submissions for Looe so I will keep mine short in comparison, the are; 1. Further large scale development, Looe infra structure is not able to cope with further development without major investment and with recent events of landslips and floods I believe that more careful consideration is needed with the allocation of new housing in Looe. Currently the Health Centre capacity is being pushed to the limits with them having to move nurses out to another location to provide space for doctors, parking and access to the site is difficult and the patients car park is leased to the town council to provide much needed patient car parking for free. The sewage works locally is not adequate for the job and again major investment is needed to secure the local bathing water quality as in 2015 new EU regulations start and the bathing water quality will directly hit the towns economy. Currently there is no NHS dentist in the town and residents have a choice of going private or travelling sometimes up to 30 miles to get this service any new developments would add to this problem. Currently the two mains roads into the town the B3253 and the A387 are subject to closure because of landslips and they suffer because they were not built to carry 44 tons vehicles and both have stretches were articulated vehicles have extreme trouble in passing. 2. Wind turbines are becoming a big issue within the community and to see if this has or would have an effect on our major industry I took the time to ask visitors to the town do you like them, we have one in full view at the back of west Looe. From the responses I got I am able to say that there is a clear view that visitors do not overall like having turbines spoil the view (their comment not mine) and as such I feel it would be better to have these in groups in places less likely to affect the views in tourist areas.

3. The historic environment is not mention for Looe whilst it is for other areas, I believe that ANOB, AGLV and the coastal zone should be kept for the area to stop development in our areas of greatest asset. I would ask that better consideration is given to this use of modern specialist design UPVC windows in the conservation area as the historic buildings in the town are of thick wall design and suffer from damp (many built on sand). Thus there thermal insulation with wood windows are poor and the costs to residents is high, wood windows for street level areas in the conservation area only. The conservation area for Looe should be better protected and smaller to help the town keep it’s unique selling point for the tourism industry.

4. Affordable housing for local people, with the talk of sustainable communities and

the effects on families of having to move away from their communities to find housing is breaking up the social structure of many towns. If you move siblings out of communities where they were born it breaks up the natural support system and impacts on family life. The current housing allocation system fails to support the allocation for local people to keep communities together and this needs to change. Whilst I support Local needs housing and affordable housing it must be targeted on local people and to meet the local need, with the affordability within the range of local wages.

5. Flooding is a major issue within the town as Looe is the most flooded town in the

South West, I would appreciate it if possible that the town has a clear directive in the local plan for the provision of local flood defences and an outer harbour or breakwater. Whilst the Environment Agency is willing to support such a plan it needs to be in the local plan as any such development would be a economic driver to support the towns economy.

Regards Armand Toms

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R Vyvyan‐Robinson Camel Valley & Bodmin Moor Protection Society Mellingey Mill House St Issey, Wadebridge PL27 7QU 01841540511 [email protected]

Charitable Company No

9 2 1

709

Pre-submission document March 2013

Local Plan – Strategic Policies Pre-submission document representation form Please return to Cornwall Council by 5.00pm on 22 April 2013

Ref: (for official use only)

Please complete a separate sheet for each representation you wish to make (All representations will become public) Name Organisation (If relevant) Address line 1 Address line 2 Address line 3 Address line 4 Postcode Telephone number Email address

1. Personal details 2. Agent details (if applicable)

Q1. Do you consider that the Local Plan meets the legal and procedural requirements? YesX No

Q1. Please specify the reasons below

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Yes No X

Q2. Please specify the reasons below

The NPPF directs that local plans should be kept ‘up to date’. We cannot find any reference to when the plan will be reviewed. The housing numbers appear to be an estimate and should be regularly reviewed. If this was made clear criticism on housing numbers, recently very vocal, would be less.

(

Document Paragraph number Policy number Cornwall Local Plan – Strategic Sustainability Appraisal Report

(Continue on a separate sheet/expand box if necessary. Mark any additional pages with your name and address)

Cornwall Local Plan 2010 - 2030

Q3. Please set out below any concerns you have with the Local Plan including any change(s) you consider necessary to address these concerns. You will need to say how this change will address the concerns and it would be helpful if you could put forward your suggested revised wording to any policy or text and any evidence to support the change.

Please state which paragraph or policy your change refers to and specify the reasons below:

Document Paragraph number Policy number Cornwall Local Plan – Strategic P li i

14 & 15


This Society has no argument with the need for renewable energy and welcomes the many words in the document concerning the Cornish landscape. Our main concern is the lack of a clear directive on the building of wind turbines and fields of solar panels. No doubt you read you have read the ‘Planning’ the journal of the Royal Town planning Institute where Tony Fyson makes some excellent points. Local council plans must, in order to deliver development of renewable energy, give clear guidance of what will be allowed and what will not. This will help developers not to make applications for schemes that will not be accepted and help objectors not to waste time and effort opposing good plans. The following is what should be included: 1. A formula, or some other method, based on height of a turbine and distance allowed from a designated landscape. 2. Clear explanation of what the Council means by ‘cumulative effect’ with numbers and distances 3. It does not appear to be clear what distance there should be from a dwelling that has no commercial interest in the turbine. A guidance on noise would also be useful.

Pre-submission document March 2013 Q4. Did you raise this issue earlier in the plan preparation process?

Yes NoX

If yes, please specify at what stage: Q5. If your representation is seeking a change, do you wish to participate at the examination in public?

No, I do not wish to participate at the examination in publicX Yes, I wish to participate at the examination in public

If you require any assistance in completing this form or require any further explanation as to what is required please contact a member of the local planning team using the email address below or telephoning 01872 224283.

Completed forms should be submitted:

by e-mail to: [email protected]

by post to: Cornwall Council Local Plans Team Carrick House St Clement Street Truro TR1 1EB

Please submit any views to Cornwall Council using the above methods by 5:00pm on 22 April 2013.


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